Refund limitation runs from the original filing date, even where later documents complete an incomplete claim.

A refund claim filed within time remains effective for limitation purposes even if it was initially incomplete and later supported by further documents. Where the department only seeks clarifications or supporting particulars, the claim is not treated as a fresh application on the date of completion. The relevant date is the date of the original refund filing, not the date on which the application is perfected after departmental requisition. On that basis, the limitation objection was unsustainable and the refund could not be rejected as time-barred.

---

---

Issues: Whether the limitation period for a refund claim is to be computed from the date of the initial refund application when the claim was first filed, though incomplete, and later supported by additional documents.

Analysis: The refund claim was initially lodged within time, and the later correspondence from the department did not reject the claim but only sought clarifications and supporting particulars. A refund application cannot be denied as time-barred merely because it was not filed in the prescribed form or was supported later by documents. The relevant date for limitation is the date of the original refund claim, not the date on which the claim is completed after departmental requisition. The authorities below therefore erred in treating the claim as barred by limitation.

Conclusion: The limitation objection was unsustainable, and the refund claim could not be rejected on the ground of time-bar. The issue is decided in favour of the assessee.

---